Course ID: OBIN

What H.R.1, “OBBBA” (Commonly Known as “The Big Beautiful Bill Act”) Means for You and Your Clients: International Tax Update

Legislation reshapes U.S. taxation of cross-border payments, modifies withholding and surtax structures, and eliminates key thresholds under prior law. Attendees will learn how these reforms alter planning for corporations, partnerships, trusts, and exempt organizations with international exposure. The program will highlight the expanded surtax on certain foreign payments, the interaction of OBBBA provisions with the Base-Erosion and Anti-Abuse Tax (BEAT), and the compliance impact on U.S. companies with foreign shareholders. Practitioners will gain insight into exceptions for U.S. multinationals and funds, as well as the broader risks and reporting obligations created by the new law.

In-person and live webcast CPE credit: up to 1.0
On-demand / self-study CPE credit: 1.0

Learning Objectives

After completing this course, you will be able to:

Identify how OBBBA expands surtaxes on U.S. payments to foreign recipients
Recognize the elimination of gross receipts and base erosion thresholds under prior law
Apply the revised rules to U.S. corporations with majority foreign ownership
Determine when the Majority U.S. Owner Exception applies
Assess how partnerships, trusts, and private foundations are impacted by new surtax provisions
Evaluate planning considerations under the modified BEAT framework
Assess and prepare to advise clients on compliance and reporting obligations created by the new law
Identify risks and opportunities for U.S. multinationals and investment funds

Major Topics

OBBBA surtax on foreign payments (IRC §899)
Increased withholding and gross-basis tax rates on U.S.-sourced payments
Removal of $500M gross receipts and 3% base erosion thresholds
Application to U.S. corporations, partnerships, trusts, and private foundations
Interaction with Base-Erosion and Anti-Abuse Tax (BEAT)
Majority U.S. Owner Exception for U.S. multinationals and funds
Compliance requirements and reporting risks
Planning implications for cross-border transactions

Advanced Preparations

None

Who Should Attend

CPAs, EAs, tax professionals

Fields of Study

Taxes

Prerequisites

Basic understanding of federal individual and estate tax law

Provider

Business Learning Institute

CPE Credits

1.0

Level

Update

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